文档介绍:Standard I: Professionalism
Standard
A. Knowledge of the Law
Understand ply with all laws, rules, regulations (including Code & Standards) of any government, regulatory agency, association governing professional activities
Comply with more strict law, rule, regulation
Do not knowingly assist in violation, otherwise dissociate from activity
Guidance
A. Knowledge of the Law
Most strict
First – notify supervisor pliance
May confront wrongdoer directly
Dissociate if necessary
Inaction may be construed as participation
No requirement to report violations to governmental authorities, but this may be appropriate in certain cases
Keep informed, regularly review pliance procedures, maintain files
pliance / legal advice as needed
Encourage firms to adopt code of ethics
Distribute information internally on applicable laws, regulations
Have written procedures for reporting suspected violations
Standard
B. Independence and Objectivity
Use reasonable care, judgment to achieve, maintain independence in professional activities
Do not offer, solicit, accept pensation that promise independence, objectivity
Guidance
B. Independence and Objectivity
Modest gifts OK
Distinguish between gifts from clients and gifts from entities trying to influence
May accept gift from clients – must disclose to employer – must get permission if gift is for future performance
Investment banking relationships – do not bow to pressure to issue favorable research
For issuer-paid research, flat fee structure is preferred
mended Procedures
B. Independence and Objectivity
Protect integrity of opinions – reports should reflect unbiased opinion
Create a restricted list
Restrict special cost arrangements
Limit gifts
Be careful with IPO share allocations
Standard
C. Misrepresentation
Do not make misrepresentations relating to investment analysis, mendations, actions or other professional activities
Guidance
C. Misrepresentation
Standard